The problem
A compliance labyrinth of EU battery, waste and EPR rules.
Union law sets the duty. Member State registers, authorisation and site law finish it. Producers, recyclers and owners have to walk the whole path — or remain non-compliant.
Open each station for the citation, what it requires, and how it sits on the path.
Entrances — EU regulations
- 01Battery RegulationRegulation (EU) 2023/1542
- 02Art. 58(7) guaranteeRegulation (EU) 2023/1542, Art. 58(7)
- 03ESPR / DPPRegulation (EU) 2024/1781
- 04Waste Framework DirectiveDirective 2008/98/EC, Art. 15
- 05Waste Shipment RegulationWaste Shipment Regulation (currently Regulation (EU) 2024/1157)
- 06ADRADR (UNECE)
- 07Annex XII / 2025/606Regulation (EU) 2023/1542, Arts. 70–71, Annex XII; Delegated Regulation (EU) 2025/606
Near the exit — member-state and regional rules
Compliant — LOOBA’s Battery EPR Reserve is the path out. Open the solution.
Union layer
The path starts in the Official Journal.
Regulation (EU) 2023/1542
Regulation (EU) 2023/1542 on batteries and waste batteries
Directly applicable in all Member States. It replaces Directive 2006/66/EC on a staged timetable and sets sustainability, due-diligence, EPR and end-of-life rules for batteries placed on the EU market — portable, SLI, LMT, EV and industrial, including stationary storage.
Regulation (EU) 2023/1542, Art. 58(7)
Article 58(7) — financial guarantee
Producers, and appointed PROs, must provide a guarantee covering waste-management costs in the event of non-compliance with EPR obligations, including permanent cessation of operations or insolvency. Member States may add further requirements.
Regulation (EU) 2024/1781
Ecodesign for Sustainable Products Regulation (EU) 2024/1781
ESPR makes Digital Product Passports the general instrument for most physical goods. Batteries do not wait for product-specific delegated acts: their passport is already fixed in the Battery Regulation. ESPR also requires a DPP registry for unique identifiers, including those used for batteries.
Directive 2008/98/EC, Art. 15
Waste Framework Directive — duty of care
Article 15 of the Waste Framework Directive sets the duty of care for waste. Collection and transport of waste batteries from site to treatment have to sit inside that duty — alongside the Battery Regulation’s own take-back and treatment rules.
Waste Shipment Regulation (currently Regulation (EU) 2024/1157)
Waste Shipment Regulation
Where waste batteries move across borders to an approved recycler, the Waste Shipment Regulation governs the shipment. The LOOBA catalogue names this instrument without a number; the Union recast in force is Regulation (EU) 2024/1157, replacing Regulation (EC) No 1013/2006.
ADR (UNECE)
ADR — carriage of dangerous goods
Waste batteries are dangerous goods for transport. ADR sets the packing, labelling, documentation and carrier rules for road carriage. It is not an EU regulation, but it binds the movement that EPR take-back actually requires.
Regulation (EU) 2023/1542, Arts. 70–71, Annex XII; Delegated Regulation (EU) 2025/606
Treatment targets and Delegated Regulation (EU) 2025/606
Articles 70 and 71, with Annex XII, set recycling-efficiency and material-recovery targets (for example 65%→70% lithium recycling efficiency and 50%→80% lithium material recovery). Delegated Regulation (EU) 2025/606 is the verification layer named in the LOOBA service catalogue.
Member-state layer
Near the exit the rules become national and regional.
Article 55 registration, national EPR authorisation, and — for ground leases — civil, environmental and lease law sit outside a single EUR-Lex page.
Regulation (EU) 2023/1542, Art. 55
Member State registers
The Battery Regulation is directly applicable, but producers must still be registered in every Member State where the battery is placed on the market. Registers, portals and filing practice are national. That is where a Union obligation becomes a stack of local procedures.
Regulation (EU) 2023/1542, Arts. 54–58; Member State measures
National EPR authorisation
Producers must be registered and, where they fulfil EPR individually or through a producer responsibility organisation, authorised. Chapter VIII applies from 18 August 2025. Member States may add further requirements to the Art. 58(7) guarantee. Authorisation practice, appointed PROs and national waste authorities differ.
Outside Regulation (EU) 2023/1542
Site, lease and regional law
Civil works, balance-of-plant, land restoration and landlord security sit entirely outside the Battery Regulation. They are governed by general civil, environmental and lease/contract law — often regional as well as national — and by the ground lease itself.